HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP

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HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
HOW GREEN ARE BIOFUELS?
Understanding the risks and
policy landscape in Indonesia

April 2021
HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
CONTENTS

    Authors                  04      Introduction

    Hugo Rosa da Conceição   05      Biofuel policy in Indonesia
    Nur Arifiandi
    Helen Finlay             11      Disparities between Indonesia’s biodiesel and
    Jodie Hartill                    environmental regulations

    Acknowledgement:         14      Transparency of Indonesian biofuel producing
                                     companies and its impacts on forests
    Pietro Bertazzi
    Thomas Maddox            16      Conclusions and policy recommendations
    Rini Setiawati
    Wisnu Wibisono           18      Annex
    Traction Energy Asia
                             19      References

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HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
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HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
INTRODUCTION

    There have been longstanding issues with deforestation in Indonesia, home
    to some of the largest tropical hardwood rainforests and peatland expanses
    on the planet. Since the 1960s forests have been subject to commercial-scale
    exploitation, in particular the conversion of primary forests, which have been
    under sustained pressure from logging, timber extraction, and conversion to
    palm oil.

    Yet according to the government, there has been signs of recent progress, with
    deforestation rates in 2020 falling to its lowest level since monitoring began
    in 19901. This progress can be attributed to policies such as the Government
    of Indonesia's moratorium on clearing primary forests and issuing licenses for
    new oil palm plantations, against a backdrop of declining palm oil prices; an
    unusually wet year causing flash flooding and landslides across the country,
    displacing 599,272 people in Kalimantan in January 2021 alone2; and a global
    economic decline due to COVID-19, resulting in less forest-clearing activities.

    The Indonesian government has publicly stated its ambition for balancing
    environmental sustainability with social welfare and economic growth, as
    outlined by the BAPPENAS Green Growth Plan. Commitments to address
    deforestation, seen as one of Indonesia’s primary environmental and social
    challenges, are a central part of this.

    The government aims to reduce carbon emissions by reducing consumption of
    imported carbon-intensive fossil fuels. Since 2006, the government has issued
    several regulations to increase consumption of biofuels, particularly from
    palm oil-based biofuel.

    As an agricultural commodity, palm oil plays a vital role in the development
    of the Indonesian economy. However, if palm oil-based biodiesel is set to
    take over from fossil-fuel energy consumption then its sustainability is of
    central concern. The issue of biodiesel is inseparable from the challenges
    that continue to surround palm oil, which remains one of the driving causes of
    deforestation in Indonesia3.

    The sustainability of biodiesel will only succeed with coherent policy direction
    to support Indonesia’s energy targets. This brief outlines potential policy
    conflicts and makes recommendations on how best to avoid them. It also
    provides an assessment of the environment-related corporate transparency
    of biofuel production for internal consumption in Indonesia, one of the several
    relevant measures required to ensure that the production of biofuels is
    deforestation-free.

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HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
BIOFUEL POLICY IN INDONESIA

Biofuels in Indonesia: background and context

Fuel demand in Indonesia is growing rapidly. Oil                    on fossil fuels and to absorb excess supply of palm oil;
consumption in the transport sector has risen from 10,711           a biodiesel mandate of 100% palm oil by 2026 would
kilotonnes of oil equivalent (ktoe) in 1990 to 51,490 ktoe in       eliminate its need for fossil fuels entirely.
20184. The consumption of oil products in the transport
sector (gas/diesel and motor gasoline) has constantly               Indonesia is the largest palm oil producer in the world
increased in the last decades, while the consumption                producing more oil palm fruit than the other nine
of other oil products remains steady or decreased. The              countries in the top 10 put together (see Figure 1). 69% of
increase in oil consumption in Indonesia was driven                 the country’s production is exported, mostly to India7.
by automotive fuel demand. Despite being part of the
Organization of Petroleum Exporting Countries (OPEC),
Indonesia became a net importer of oil in the 2000s5,               Figure 1: Top 10 oil palm fruit producers worldwide,
representing an increasing burden on the country’s                  20198
budget. To reduce those expenses and its increasing
dependence on imported fuel in a context of growing                    Indonesia
demand, Indonesia has, since 2006, turned to biofuels                     Malaysia
from palm oil. With a larger yield than any other source
                                                                          Thailand
of vegetable oil, palm oil is an ideal crop for biofuels from
a production standpoint. It is cheaper than any other                       Nigeria
vegetable oil used in biodiesel production, is a perennial                Colombia
crop with a long life cycle of 25 years, productive over a
                                                                     Guatemala
significant duration of time6 and, more importantly, is a
                                                                    Papua New
widely established crop in Southeast Asia.                              Guinea
                                                                            Ghana
The proportion of domestically consumed palm oil used
                                                                             Brazil
for biofuel production in Indonesia has grown as a result
                                                                       Honduras
of policy incentives to reduce the country’s dependency
                                                                                      0       50     100        150     200      250      300
                                                                                                          Millions of Tonnes

      Guatemala                                                                                              Thailand
                      Honduras
                                                     Nigeria                                                            Malaysia
                  Columbia                                                                                                    Indonesia
                                           Ghana
                                                                                       Papua New Guinea
                             Brazil

                                                                Country

                                                0         Millions of tonnes          300

                                                                                                                                                5
HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
Indonesia’s palm oil is mostly produced in private lands.   nationwide11. For that reason, Indonesia’s decision to
    Estates owned by large producers account for the            ramp up biofuel production will lead to a higher demand
    production of 53% (8.68 million ha) of the country’s palm   for palm oil, which will result in increased pressure on
    oil, whilst smallholder palm oil production accounts for    existing forests. Further loss of forests threatens the
    40% (6.72 million ha)9. Government estates account for      rich biodiversity in this vulnerable landscape, could
    only a small part of the production. The total area used    exacerbate GHG emissions, divert palm oil from the
    for the production of palm oil in the country has grown     food chain and expose those living in converted lands
    from 4 million ha in 2000 to 14 million ha in 201910.       to extreme climate change events. The remainder of
                                                                this section will present the most relevant regulatory
    Palm oil expansion has been linked by some studies as       developments in the biofuels sector in the country,
    a driver of deforestation in Indonesia. Recent research     exploring how those regulations might affect biofuel
    states that, between 2001 and 2016, oil palm plantations    producing companies.
    may have caused 23% of the total deforestation

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HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
Biofuel regulation development in Indonesia

The development of biofuels in Indonesia started in 2006          2008 saw a major development in Indonesia’s biofuel
when the government issued the National Energy Policy12,          policy. The Minister of Energy and Mineral Resources
which established that biofuels should comprise at least          (MEMR) established15 the mandatory utilization of biofuels
5% of the country’s energy mix by 2025. Indonesia further         in the transportation, industrial, commercial, and electricity
developed its energy regulations with a law13 aimed at            generation sectors, with a progressive target for biofuel
further reducing the country's dependence on imported             blending over the 2008–2025 period16. The regulation also
refined oil, while boosting the use of other energy sources,      established that “enterprises performing trading business
including biofuels14.                                             activities on biofuel as alternate fuel must possess a
                                                                  business permit”17 issued by the ministry.

   Blending targets
   In order to introduce biofuels into transportation fuel, it is commonly blended with fossil fuels in different
   concentrations. A mixture of 5% biofuels and 95% fossil-based diesel is usually called B5, one with 20% biofuels is
   called B20 and so forth. In 2020, the Indonesian government has a target of 30% biofuels in the fossil-based diesel,
   sometimes referred to as the B30 program.

Table 1: Main biofuel-related regulations in Indonesia

       Year                      Document                                              Main contents
                                                         Promote the supply and increased consumption of biofuels with the goal
      2006         Presidential Instruction No. 1
                                                         of replacing fossil fuels

      2006         Presidential Regulation No. 5         Biofuels should comprise at least 5% of the country’s energy mix by 2025

                                                         Achieve Indonesia’s energy independence, boost the use of other energy
      2007         Law No.30 of 2007
                                                         sources, including biofuels
                                                         Mandatory utilization of biofuel in the transportation, industrial,
      2008         MEMR Regulation No. 32                commercial, and electricity generation sectors, with a progressive target
                                                         for biofuel blending.
                                                         Sets certain sector industry obligations/ mandatory to use biodiesel and
       2015        MEMR Regulation No. 12
                                                         bioethanol as a fuel mixture, revises regulation No. 32
                   Ministry of Agriculture Ministerial   Exempts palm oil plantations supplying palm oil for biofuel production
       2015
                   Regulation No. 11                     from ISPO compliance
                   Presidential Regulation No. 22 –      Establishes the national strategic plans for cross-sectoral energy planning
      2017
                   National Energy General Plan (RUEN)   and coordination
                                                         Makes mandatory for all Fuel Business Entities to mix biodiesel with diesel
      2018         MEMR Regulation No. 41
                                                         fuel based on the minimum percentage set by law.

      2020         Presidential Regulation No. 44        Updates guidelines for the ISPO

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HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
Blending targets

    Between 2013 and 2015, biofuel blending targets18 were        the economic slowdown from the COVID-19 pandemic,
    amended several times19. Table 2 shows how these              the government of Indonesia is still pressing ahead with
    targets have changed. The responsibility for meeting          the B30 program and aiming to launch the B40 program
    these targets falls on companies20.                           in 202228. In parallel, the government is also in the testing
                                                                  stage to develop D100 (green-fuel 100% plant-based) and
    Table 2: Indonesian Biofuel blending targets for most         this is expected to start production by 2023. The program
    sectors21                                                     is estimated to consume 30 million tonnes of Crude Palm
                                     Year
                                                                  Oil (CPO) annually29.

                2009   2010   2014   2015   2016   2020 202222
                                                                  Biofuel subsidies
     Blending
                1%     2.5%   10%    15%    20%    30%   40%
     % target                                                     Low global oil prices have necessitated government
                                                                  subsidies to support blending targets, due to the price
                                                                  of biodiesel being higher than the base diesel fuel
    Despite current policy incentives, Indonesia was falling      price30. These subsidies have been issued through
    short of biofuel blending targets until 2020. In 2018, it     the Indonesian Oil Palm State Fund (BPDPKS), which
    stood at 12.7%, well below the 20% target23. Researchers      provides a subsidy to biofuel producers31. The amount
    identified that regulations are not effectively enforced      paid is the price differential between fossil-based diesel
    and that it “is not seen as a binding mandate, especially     and biofuels32. Not all producers are able to receive
    for fuel suppliers not receiving subsidy funds24". In a bid   a subsidy however, with the government selecting
    to accelerate the achievement of the B20 mandate, in          producers who meet production requirements and
    2018 the MEMR required25 the blending of the minimum          allocating amounts to be produced by them33. The Annex
    percentage set by law in all sectors. The regulation states   at the end of this briefing shows allocations from 2019 to
    that the B20 mandate applies to diesel fuel processing        2021.
    and trading/importing companies for both subsidized
    and non-subsidized diesel fuel. Failure to comply with        The subsidy is financed by tariffs on palm oil exports,
    regulations can result in fines to the revocation of          yet a decrease in the price of this commodity in the last
    the company’s diesel fuel processing and/or trading           year due to COVID-19 has resulted in a financial shortfall
    license26.                                                    of around 195 million USD that will need to be taken
                                                                  from the state budget. The biodiesel subsidy is set to be
    In 2020, the expected blended target by MEMR regulation       part of the government’s COVID-19 recovery plan, with
    no.12/201527 has been achieved, with the blending mix         Finance Minister Sri Mulyani Indrawati estimating that
    of biodiesel B30 starting implementation nation-wide.         a total of 250 million USD will be needed to keep the
    Despite biodiesel consumption being predicted to decline      biodiesel program afloat34,35.
    around 13% from the allocated production in 2020 due to

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HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
Regulatory incentives to increase biofuel                      Palm oil certification
production
                                                               There are sustainability certification schemes for palm
The stage is set for increased biofuel production, so how      oil production applicable in Indonesia, such as the
does current policy facilitate anticipated expansion?          voluntary Roundtable on Sustainable Palm Oil (RSPO),
                                                               which through multi-stakeholder governance issues a
{ Companies receive financial incentives to boost their
                                                               global standard, and the Indonesia specific, mandatory
  biofuel production.
                                                               ISPO. There is, however, no specific regulation on
{ Company revenue is protected by biofuel subsidies.           sustainability criteria for domestically consumed
{ At plantation level, biofuel producing companies             biodiesel37. On the contrary, between 2015 and 2020,
  did not incur ISPO fees for compliance verification          the Ministry of Agriculture specifically exempted palm
  between 2015 and 2020.                                       oil plantations supplying palm oil for biofuel production
                                                               from compliance with the ISPO38. In a positive
Therefore, as table 3 shows, these factors have                development the rules for the implementation of the
contributed to the increasing number of biorefineries,         ISPO were changed in 2020 to mandate most oil palm
and their subsequent capacity to produce biofuel, and          plantations once again in Indonesia, including those for
ultimately the utilization of the higher supply.               biofuel production, to comply with ISPO.

Table 3: Biodiesel Utilization and capacity in Indonesia - 2009-201836

                                                                            Year
                               2009     2010     2011       2012    2013       2014     2015    2016     2017     2018

   Blending % target            1%      2.5%     2.5%       2.5%     2.5%      10%      15%      20%      20%      20%

   Blend rate                  0.39%    0.66%    1.10%      1.81%   2.93%      5.42%    2.61%   10.78%   8.85%    12.7%

   Biodiesel on-road use
                                 95      178      287       535      838       1,476    665     2,621    2,272    3,650
   (Million liters)

   # of biorefineries            20      22       22         22       26           26    27      30       32       31

   Total biodiesel industry
                               3,128    3,921    3,921      4,881   5,670      5,670    6,887   10,898   11,547   11,357
   capacity (Million liters)

                                                                                                                           9
HOW GREEN ARE BIOFUELS? - Understanding the risks and policy landscape in Indonesia - CDP
Ensuring environmental safeguards

     An increase in production and capacity is likely to pose        Even when biofuel policies show good intentions
     a major threat to Indonesia’s forests if not managed            towards reducing the environmental impact of increased
     and monitored carefully. The margin for error is                production, they fall short regarding implementation
     small, regulation that aims at stimulating an increase          details. Indonesia’s 2006 biofuel plan proposed an
     in the production of palm oil must have significant             expansion of palm plantations towards unproductive
     environmental safeguards. A recent report from Coaction         or damaged forest lands40. The intended increase in
     Indonesia shows that “looking at the projected demand           production would require more than 10 million hectares
     for biodiesel, it can be concluded that the demand for          of land, as identified by a report from the government’s
     domestic CPO will continue to increase. This increase is        National Biofuel Team (Timnas BBN). The same report,
     also directly proportional to land requirements, especially     however, “only identified 0.3 million hectares of degraded
     because the average productivity per hectare is still low39".   land as suitable for biofuel production, exposing a large
                                                                     gap between the amount of biofuel that can be produced
     The lack of mandatory certification, the provision of           without causing environmental damage and what would
     subsidies, and the aggressive regulatory push for more          be required under the Timnas BBN plan41".
     oil palm production (e.g., fines for B20 non-compliance)
     create conditions for producers to maintain business-as-        Crucially, biofuel policies are also often at odds with
     usual production systems instead of investing in more           stated environmental objectives set by the Indonesian
     sustainable production innovations, such as increasing          Government. The next section will analyze the
     land productivity. Therefore, biofuel regulations in            contradictions between the environmental risks posed by
     Indonesia, as they stand, may lead to increased pressure        the regulatory framework driving biofuel expansion and
     on Indonesian forests.                                          the targets set by the Indonesian government to reduce
                                                                     deforestation and emissions.

10
DISPARITIES BETWEEN INDONESIA’S BIODIESEL
AND ENVIRONMENTAL REGULATION

The production of biodiesel shows growing trends in the country, almost doubling
the production in the past 10 years42. Based on these developments, the Indonesian
government prioritized the development of biodiesel and set a target to increase
production, with 15 million kilo Liter (mkL) to be produced by 2030 and 54.2 mkL
by 2050. To support the achievement of that target, the government will allocate
4 million ha of area to support biodiesel production by 202543. Parallel with the
government's ambition in increasing the development of the biodiesel program, a
series of environmental commitments and targets, as well as regulations to limit
deforestation has been decreed by the government.

Moratorium on new palm oil plantations                        Palm oil productivity (Oil Palm Plantation
                                                              Rejuvenation Program)
Presidential Instruction No.8/2018 established a
moratorium on permits for new palm plantations for 3          Increased plantation productivity is seen as one of the
years, as well giving the government authority to review      alternatives to produce more palm oil without increasing
existing licenses and revoke them if the area has not         the planted area. Productivity, however, has long been
yet been cleared44. It aims to promote better palm oil        an issue in Indonesia, with a particularly stark gap
governance, reduce greenhouse gas emissions from              between private companies and smallholders. The
land use change, and increase palm oil productivity. The      low intensification, and often unsustainable farming
effectiveness of the moratorium is, however, questionable,    practices, along with less government support for
as data from the Ministry of Agriculture show that the area   smallholders46, results in smallholders producing on
of plantations expanded from 14 million hectares in 2018      average 2-3 ton/ha/year, while private companies
to more than 16 million in January 202045.                    producing on average 4 ton/ha/year47.

                                                              To address low productivity, the Indonesian government
                                                              launched the Oil Palm Plantation Rejuvenation48 program
                                                              (Peremajaan Sawit Rakyat - PSR) in 2017. By 2020, only
                                                              11%49 of the program’s total target has been achieved.
                                                              There are concerns of a lack of clear targets and clear
                                                              guidance on how to increase smallholder productivity50.
                                                              The government is also considering stopping the blending
                                                              program at a maximum 50% blend if there is no further
                                                              improvement on the production yield of the palm oil51.

                                                              Without a significant improvement in palm oil productivity,
                                                              the current blended biodiesel target could potentially
                                                              drive 4.5 million hectares in additional forest loss52. These
                                                              losses will likely rise with increased biofuel production to
                                                              curb the country’s current daily consumption of 1 million
                                                              barrels of gasoline, as the Minister of Mineral and Energy
                                                              Resources warned in December 2020. An additional 9 to
                                                              15 million ha of new palm oil plantations53 is expected to
                                                              be required to meet demand.

                                                                                                                              11
Omnibus law                                                   Renewable Energy

     In 2020, the Indonesian House of Representatives              Another path aimed by the government to reduce
     approved the Job Creation Law (Law No. 11/2020 on             emissions is upscaling the development of renewable
     Job Creation, commonly known as the “Omnibus Law”).           energy. The Energy sector has been targeted to reduce
     The Omnibus Law amends several sectors, including             314-398 Mt CO2e from the business as usual (BaU)
     the environment and forestry sectors, allowing the            emission (1,669 Mt CO2e) by 203057, of which 54%
     government to approve agribusiness investment in              (170.42 Mt CO2e) is to be achieved by contributions
     designated forest and peatland areas that are currently       from renewable energy58. These plans align with the
     protected by a deforestation moratorium. Moreover,            Indonesian government’s objective of having renewable
     the bill eliminates the legal requirement to maintain a       energy covering 31% of the country’s primary energy mix
     minimum of 30% primary forest cover on provincial             by 2050 (23% by 2025), as stipulated under the National
     land and waivers the legal liability for companies that       Energy Regulation (KEN)59. In 2017, to support the
     experienced fires on their concession areas54.                implementation of KEN, the government has published
                                                                   National Energy General Plan (RUEN)60.
     While the Omnibus Law may increase attractiveness to
     invest in Indonesia due to easier capital flows55, it could   REDD+
     escalate the risk of deforestation and to customary
     land use rights. Sectors such as palm oil have made           Indonesia has been involved with Reducing Emissions
     progressive efforts to reduce forest destruction through      from Deforestation and Forest Degradation (REDD+)
     “No Deforestation, No Peatland, No Exploitation”              from an early stage. REDD+ has led to numerous
     (“NDPE”) policies, which may be reduced in significance       achievements, especially regarding a better
     as a result of the Law. Despite the growing push for          understanding of the underlying drivers of deforestation,
     financial institutions to reduce their contribution to        but progress has been slower than hoped, mainly due to
     deforestation, the political outlook also needs to            susceptibility to political turnover at each election cycle,
     be consistent to enable both economic growth and              focus on technicalities rather than on directly addressing
     sustainable practices for plantations.                        drivers of deforestation, varying rates of progress at the
                                                                   subnational level, among other issue61.
     Nationally Determined Contribution (NDC)

     In addition to those policies, Indonesia has other
     overarching environmental targets that might be affected
     by a potential increase in palm oil production. The most
     relevant of them is Indonesia’s NDC which commits to
     reduce Indonesia’s GHG emissions by 29% on its own
     efforts, and up to 41% with international support56.

     Considering that main contributing sector for Indonesia’s
     emissions is Land-use Change and Forestry (LUCF), an
     important part of the committed reductions will have to
     come from that sector. Actions to reduce deforestation
     and forest degradation are integral parts of the NDC,
     although no specific actions on palm oil are mentioned
     in the NDC for the LUCF sector.

12
Policy incoherence is a risk

The policies described above represent important and            was originally conceived as an alternative to increase
positive commitments towards reducing deforestation             Indonesia’s fuel security, as part of the country’s
and GHG emissions in Indonesia. However, the policies           renewable energy strategy, and as an additional
in place to expand the production of biofuels, described        contribution to reduce carbon emissions and support the
in Section 1, have the risk of contradicting the country’s      Paris Agreement’s and SDGs’ commitments.
sustainability efforts. The expansion of palm oil plantations
required to provide the necessary raw material for biodiesel    For it to be sustainable and categorized as a renewable
production in Indonesia is likely to increase pressures on      energy source, biofuel production requires coherent
Indonesia’s forests, being thus counterproductive to the        policies among government sectors and the adoption
Indonesia’s sustainability objectives.                          of stringent forest safeguards within the raw material
                                                                supply chain. Transparency regarding the environmental
Unless the sourcing of biodiesel is deforestation-free,         aspects of biodiesel production is one among several
its claimed “green fuel” status is both inaccurate and          actions required to achieve a deforestation-free biodiesel
misleading. The production of plant-based diesel                supply chain.

                                                                                                                             13
TRANSPARENCY OF INDONESIAN BIOFUEL
     PRODUCING COMPANIES AND ITS IMPACTS
     ON FORESTS
     This section will provide an assessment of Indonesian Biofuel producers in terms
     of their environmental transparency. A variety of measures is required to ensure
     that companies to adopt more environmentally responsible behaviors. Increased
     transparency is one of them, and it promotes sustainability in several ways:
     { allows both customers and stakeholders to assess                      The majority of companies supplying the B20/B30
         progress on companies’ deforestation commitments,                   program are subsidiaries of larger companies; the 20
                                                                             supplying companies represent 10 larger companies,
     { facilitates the risk assessment and identification                    5 of which are listed as amongst the world’s largest
         of opportunities by investors and purchasing                        traders/processors in a recent situational analysis
         companies,                                                          commissioned by CDP64. This concentration is likely
     { fosters compliance with regulatory requirements,                      caused by the large capital requirements for refinery
                                                                             ownership65. Of the companies in table 4, only three
     { strengthens accountability,                                           scored either an A or B (good) in their disclosure to CDP;
     { improves the dialogue between private and public                      these companies also displayed a higher SPOTT score
         entities and protects smallholders.                                 than the other companies. This shows that whilst certain
                                                                             companies perform well, there is significant opportunity
     The assessment does not intend to be exhaustive; it will                to improve reporting of standardized information by the
     assess the companies, shown in Table 4, appointed to supply             sector to support traceable and sustainable palm oil.
     biodiesel to the B20/B30 program in 2019 and 2020. The
     exact allocation for each producer is shown in the Annex.

     Table 4: B20/B30 program suppliers

                                                                        CDP Palm Oil     CDP Palm Oil      SPOTT 11/2020
                                      Parent         Headquarters                                                            RSPO Member
            Supplier Name                                                Score 2019    Score 2020 (Parent (Parent Company,
                                     Company       (Parent Company)                                                        (Parent Company)
                                                                      (Parent Company)     Company)            E score)
     Smart Tbk                      Golden-Agri
                                                      Singapore              A-                A-              81.2%             Yes
     Sinar Mas Bio Energy           Resources
     Musim Mas
     Intibenua Perkasatama          Musim Mas         Singapore              B                 B               85.7%             Yes
     Sukajadi Sawit Mekar
     Wilmar Bioenergi Indonesia
     Wilmar Nabati Indonesia          Wilmar
                                                      Singapore              B-                A-              88.9%             Yes
     Multi Nabati Sulawesi         International
     Energi Unggul Persada
     Cemerlang Energi Perkasa
                                      Apical63        Singapore             N/A                B               82.5%            Yes63
     Kutai Refinery Nusantara
     Batara Elok Semesta Terpadu    BEST Group        Indonesia              F                 F               1.8%              No
     Darmex Biofuels
     Bayas Biofuels                Darmex Agro        Indonesia              F                 F               1.3%              No
     Dabi Biofuels
     Pelita Agung Agrindustri      Permata Hijau
                                                      Indonesia              F                 F               37.2%             Yes
     Permata Hijau Palm Oleo          Group
                                   PT Tunas Baru
     Tunas Baru Lampung                               Indonesia              F                 F               14.2%             Yes
                                     Lampung
                                   Louis Dreyfus
     LDC Indonesia                                   Netherlands             F                 F               62%               Yes
                                     Company
                                       First
     Ciliandra Perkasa                                Singapore              F                 F              64.08%             Yes
                                    Resources
14
CDP Disclosure                                               Roundtable on Sustainable Palm Oil (RSPO)

The analysis focuses on parent companies since none          Among several other requirements, participation in the
of the subsidiaries have been invited to disclose to         RSPO certification scheme is another indication of a
CDP66. Golden-Agri Resources, Musim Mas and Wilmar           company’s willingness to increase transparency. RSPO,
International received good scores for their Palm Oil        through stringent certification and global setting of
disclosures (from B- to A) in 2019 and 2020, with Wilmar     standards via multi-stakeholder involvement, intends to
International improving from B- to A- in 2020. Six of the    ensure the credibility of palm oil sustainability claims70.
ten parent companies, including all four headquartered in    Most biofuel suppliers reviewed in this briefing are
Indonesia, received a F score in both years, they did not    members of the RSPO, with exception of Darmex Agro
disclose to CDP.                                             who had its membership terminated in 2013 by an
                                                             RSPO Complaints Panel decision due to its plantation
Golden Agri-Resources, which received an A- score,           subsidiary, PT Duta Palma Nusantara, planting on
reports that two biodiesel plants have received ISCC         peatland, clearing forest without a High Conservation
(International Sustainability and Carbon Certification),     Value (HCV) assessment, and using fire for clearing71. The
and that all biomass intended for biofuels in destinations   RSPO ACOP is the mandatory report issued by members
such as Europe are ISCC certified. However, it does          to demonstrate their progress towards 100% sustainable
not provide information related to biofuels intended for     palm oil72. However, none of the companies’ RSPO Annual
consumption in Indonesia. Apical, Wilmar International,      Communication of Progress (ACOP) for 2019, the latest
and Musim Mas reported that biofuels are part of their       publicly available, displays specific information on biofuels.
business activities, but also did not provide additional
information on domestic consumption in Indonesia.

Sustainability Policy Transparency Toolkit
(SPOTT) Evaluation

Another important evaluation of environmental
transparency in the Palm Oil sector is performed by
SPOTT67. It assesses “palm oil producers, processors,
and traders on the public disclosure of their policies,
operations and commitments to environmental, social
and governance (ESG) best practice68". The scores
shown in Table 4 are the environmental scores of the
companies. SPOTT defines transparent information
as “information communicated by a company via
publicly available materials that are freely and readily
accessible to all stakeholders69". SPOTT’s evaluation
does not necessarily mean that a company is
effectively implementing its commitments on the
ground, but that they are being transparent in their
ESG reporting. SPOTT’s scores show great variation
between companies, with some such as Musim Mas
with very high scores (for having, among several other
sustainability indicators, a time-bound commitment to
achieve 100% traceability to mill level), and others such
as BEST Group and Darmex performing poorly.

                                                                                                                              15
CONCLUSIONS AND RECOMMENDATIONS

     Indonesia has a way to go to ensure that its biofuels program lives up to its
     green credentials. Sustainable biodiesel is at the crux of Indonesia's sustainable
     development, requiring careful policy consideration of economic, social and
     environmental issues. Government policy can improve environmental safeguards
     for palm oil production by focusing on yield rather than expansion, smallholder
     productivity and the integration of sustainability standards as the bare minimum
     in biodiesel production. By increasing public-private sector dialogue, policy can
     help to provide a pathway to better sustainability standards throughout the biofuel
     industry resulting in higher yields, more efficient use of resources, and protection
     of human rights. Setting all these actions in motion will no doubt reduce the need to
     expand plantations, causing potentially irreparable damage to biodiversity and the
     environment.

                             Policy Recommendations

                             1     Alignment of biofuel and forest policy.

                             { A lack of policy coherency threatens the government of Indonesia’s sustainability
                               commitments to the Paris Agreement and the Sustainable Development
                               Goals. Whilst Indonesia has established a moratorium on new palm oil
                               plantation licenses, the acceleration of its biodiesel program contradicts those
                               commitments as this will likely require 9 – 15 million hectares of additional
                               palm oil plantations73. The energy transition from fossil fuels to biofuels is an
                               interrelated policy challenge and should be situated within the carrying capacity
                               of the Indonesia’s forests environment to ensure long-term sustainability.

                             2     Improve environmental safeguards for palm oil production.

                             { There should be agreed cut-off dates within the Indonesian Sustainable Palm Oil
                               (ISPO) for land clearing for biodiesel feedstock. The Round Table for Sustainable
                               Palm Oil (RSPO) has a cut-off date of high conservation value clearing in 2005,
                               whilst the Forest Stewardship Council (FSC) has a cut-off date of 1994. There is
                               no such regulation within the ISPO, which is a policy gap that must be addressed
                               to prevent further conversion of forests into plantations74.
                             { Biodiesel production guidelines currently focus on the blending target and quality
                               level. The integration of sustainability aspects within the industry’s regulations
                               is still lacking and needs to be scaled up. The International Sustainability and
                               Carbon Certification (ISCC) is one of the standards that can be referred to,
                               but its uptake remains low, due to its only mandated for the European Union
                               market. While mandatory ISPO as the standard for biodiesel feedstock has been
                               introduced, its implementation needs to be better monitored.

16
3
       Enhance corporate environmental disclosure,
       including biodiesel supply chains.

{ Mandatory transparency is needed at both the parent company level as well as
  its subsidiaries. Despite environmental commitments of parent companies, even
  those leading on sustainability action, the complexity of corporate structures and
  the biodiesel supply chain hinders the ability of companies to ensure traceability
  to plantations and guarantee deforestation-free operations. Enforcing disclosure
  on environmental issues can help the government to understand companies’
  roles in the biodiesel supply chain and better identify policy intervention areas.

4     Increase public-private dialogue and cooperation.

{ To fulfill the new biodiesel demand, the government must focus on supporting
  the increase of smallholder yield production, by providing clear targets and
  guidance, as well as to support the inclusion of smallholders within the biodiesel
  supply chain.
{ Many companies in palm oil supply chains are already implementing commitments
  and NDPE policies relating to other oil palm products. They are often equipped with
  the right tools to address deforestation risks but have not used those in relation to
  their palm oil business due to lack of regulatory pressure. Increased dialogue and
  cooperation between public and private sectors can contribute towards identifying
  win-win solutions and understanding how the private sector can contribute towards
  government goals whilst meeting their commitments.

                                                                                          17
18
ANNEX

Company allocation for the B20/B30 program, 2019-2021, kL

                   2019                              202075                                 202176
    Company               Volume       Company                Volume         Company                 Volume
  Wilmar Nabati                      Wilmar Nabati                         Wilmar Nabati
                          904.431                             1.374.000                              1.375.486
    Indonesia                          Indonesia                             Indonesia
 Wilmar Bioenergi                   Wilmar Bioenergi                      Wilmar Bioenergi
                          844.949                             1.323.000                              1.324.226
    Indonesia                          Indonesia                             Indonesia
   Musim Mas              745.504     Musim Mas               1.085.000     Musim Mas                882.530
 Cemerlang Energi                    Bayas Biofuels           862.000     Cemerlang Energi
                          449.753                                                                    483.263
     Perkasa                        Cemerlang Energi                          Perkasa
                                                              483.000
  LDC Indonesia           292.927       Perkasa                            Kutai Refinery
                                                                                                     398.979
   SMART Tbk              269.914    LDC Indonesia            434.000        Nusantara
                                                                           Permata Hijau
   Sinarmas Bio                      Permata Hijau                                                   396.793
                          262.011                             417.000        Palm Oleo
      Energy                           Palm Oleo
                                                                            Multi Nabati
  Permata Hijau                       Sinarmas Bio                                                   392.996
                          261.183                             396.000         Sulawesi
    Palm Oleo                            Energy
   Multi Nabati                       Multi Nabati                         LDC Indonesia             386.610
                          253.427                             393.000
     Sulawesi                           Sulawesi                            Sinarmas Bio
                                                                                                     364.700
    Intibenua                         SMART Tbk               383.000          Energy
                          241.053
   Perkasatama                         Intibenua                            SMART Tbk                352.782
                                                              354.000
  Bayas Biofuels          229.075     Perkasatama                          Bayas Biofuels            349.180
  Kutai Refinery                      Tunas Baru                            Tunas Baru
                          220.189                             342.000                                342.311
    Nusantara                          Lampung                               Lampung
  Sukajadi Sawit                     Kutai Refinery                        Energi Unggul
                          219.677                             336.000                                318.953
      Mekar                            Nusantara                              Persada
   Tunas Baru                        Sukajadi Sawit                          Intibenua
                          216.875                             322.000                                287.944
    Lampung                              Mekar                              Perkasatama
   Dabi Biofuels          207.344   Darmex Biofuels           287.000       Batara Elok
                                                                                                     273.274
   Batara Elok                        Batara Elok                             Semesta
                          175.859                             287.000
     Semesta                            Semesta                            Sukajadi Sawit
                                                                                                      261.767
 Ciliandra Perkasa        171.854   Ciliandra Perkasa         283.000          Mekar

   Pelita Agung                       Pelita Agung                        Ciliandra Perkasa          259.882
                          145.396                             230.000
    Agrindustri                        Agrindustri                          Pelita Agung             239.215
 Darmex Biofuels          85.680                                             Agrindustri             218.618
                                                                            Dabi Biofuels            173.974
                                                                          Darmex Biofuels             116.517

                                                                                                                 19
REFERENCES

     1   Mongabay (2021). Deforestation in Indonesia Hits Record Low, but Experts Fear a Rebound, in https://news.mongabay.
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     2   Human Initiative (2021). SITREP #5 South Kalimantan Floods-Tuesday, 26 January, 2021 in https://reliefweb.int/report/
         indonesia/sitrep-5-south-kalimantan-floods-tuesday-26-january-2021
     3   Austin, K., Schwantes, A., Gu, Y., Kasibhatla, P., Https://orcid.org/0000-0002-7690-8774, K., & Https://orcid.org/0000-
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     5   Ibid
     6   Roundtable on Environmental Health Sciences, Research, and Medicine; Board on Population Health and Public Health
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         Washington (DC): National Academies Press (US) (2014) Apr 2. 2, Case Study: The Palm Oil Example, in https://www.
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     7   Badan Pusat Statistik (2020). Statistik Kelapa Sawit Indonesia 2019, in https://www.https://www.bps.go.id/
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     8   FAO (2021). FAOSTAT-Crops, in http://www.fao.org/faostat/en/#data/QC
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         luas,%20sebaran%20dan%20tantanganya.pdf
     10 Ibid
     11 Austin, K., Schwantes, A., Gu, Y., Kasibhatla, P., Https://orcid.org/0000-0002-7690-8774, K., & Https://
        orcid.org/0000-0002-7791 1078, A. (2018, December 05). IOPscience, from https://iopscience.iop.org/
        article/10.1088/1748-9326/aaf6db
     12 Peraturan Presiden (2006). National Energy Policy (Presidential Regulation No. 5/2006), in http://extwprlegs1.fao.
        org/docs/pdf/ins64284.pdf
     13 Presiden Republik Indonesia (2007). Energy Law No. 30/2007, in https://www.iea.org/policies/1858-energy-law-
        no-302007
     14 Ibid
     15 Center, P. (2008). Indonesia Energy and Mineral Policy, in https://datacenter-pyc.org/data/policy/indonesia-energy-
        and-mineral-policy/
     16 Kharina, A., Malins, C., & Searle, S. (2016,). Biofuels Policy in Indonesia: Overview and Status Report, in https://
        theicct.org/sites/default/files/publications/Indonesia%20Biofuels%20Policy_ICCT_08082016.pdf
     17 The Minister of Energy and Mineral Resources (2009). Supply, Utilization and Trading Procedure of Biofuel as
        Alternate Fuel, in http://extwprlegs1.fao.org/docs/pdf/ins88442.pdf
     18 See box page 4.
     19 Ministerial Regulation No. 12/2015.
     20 Kharina, A., Malins, C., & Searle, S. (2016). Biofuels Policy in Indonesia: Overview and Status Report, in https://
        theicct.org/sites/default/files/publications/Indonesia%20Biofuels%20Policy_ICCT_08082016.pdf
     21 Fitriani Tupa R. Silalahi, Togar M. Simatupang, Manahan P. Siallagan. Biodiesel produced from palm oil in
        Indonesia: Current status and opportunities[J]. AIMS Energy, 2020, 8(1): 81-101. doi:10.3934/energy.2020.1.81,
        and Kharina, A., Malins, C., & Searle, S. (2016). Biofuels Policy in Indonesia: Overview and Status Report, in https://
        theicct.org/sites/default/files/publications/Indonesia%20Biofuels%20Policy_ICCT_08082016.pdf
20
22 Pemerintah Targetkan Solar B40 Bisa Terealisasi di 2022, in https://otomotif.kompas.com/
   read/2020/11/13/160214115/pemerintah-targetkan-solar-b40-bisa-terealisasi-di-2022#:~:text=JAKARTA%2C%20
   KOMPAS.com%20%2D%20Kementerian,bakar%20solar%20pada%20tahun%202022.
23 Fitriani Tupa R. Silalahi, Togar M. Simatupang, Manahan P. Siallagan. Biodiesel produced from palm oil in
   Indonesia: Current status and opportunities[J]. AIMS Energy, 2020, 8(1): 81-101. doi:10.3934/energy.2020.1.81
24 Kharina, A., Malins, C., & Searle, S. (2016). Biofuels Policy in Indonesia: Overview and Status Report, in https://
   theicct.org/sites/default/files/publications/Indonesia%20Biofuels%20Policy_ICCT_08082016.pdf
25 Regulation No. 41/2008
26 Major regulatory and policy updates for the Indonesian energy sector - increased biodiesel requirements, proposed
   limitation of crude exports/imports, and potential delay of existing power projects (2018), in https://www.lexology.
   com/library/detail.aspx?g=e8471e59-288b-4f98-b6aa-56aff0130a94#:~:text=In%20August%202018%2C%20
   the%20Indonesian%20President%20issued%20Regulation%20No.&text=41%20of%202018%20(Regulation%20
   41,to%20reduce%20imports%20of%20fuel.
27 Menteri Energi dan Sumber Daya Mineral Republik Indonesia (2015). Perubahan Ketiga atas Peraturan Menteri
   Energi dan Sumber Daya Mineral Nomor 32 Tahun 2008 Tentang Penyediaan, Pemanfaatan, dan Tata Niaga Bahan
   Bakar Nabati (Biofuel) sebagai Bahan Bakar Lain, in https://jdih.esdm.go.id/peraturan/Permen%20ESDM%20
   12%20Thn%202015.pdf
28 Pemerintah Targetkan Solar B40 Bisa Terealisasi di 2022, in https://otomotif.kompas.com/
   read/2020/11/13/160214115/pemerintah-targetkan-solar-b40-bisa-terealisasi-di-2022#:~:text=JAKARTA%2C%20
   KOMPAS.com%20%2D%20Kementerian,bakar%20solar%20pada%20tahun%202022
29 Katadata (2020). Pengembangan D100 Ditaksir Mampu Serap 30 Juta Ton Minyak Sawit, in https://katadata.co.id/
   ekarina/berita/5f102960a99ad/pengembangan-d100-ditaksir-mampu-serap-30-juta-ton-minyak-sawit
30 Kharina, A., Malins, C., & Searle, S. (2016). Biofuels Policy in Indonesia: Overview and Status Report, in https://
   theicct.org/sites/default/files/publications/Indonesia%20Biofuels%20Policy_ICCT_08082016.pdf
31 Ibid
32 Fitriani Tupa R. Silalahi, Togar M. Simatupang, Manahan P. Siallagan. Biodiesel produced from palm oil in
   Indonesia: Current status and opportunities[J]. AIMS Energy, 2020, 8(1): 81-101. doi:10.3934/energy.2020.1.81
33 Indrawan, R. (2020). Pastikan B30 Tetap Jalan, Pemerintah Talangi Rp2,78 Triliun Kekurangan Dana Insentif
   Biodiesel, in https://www.dunia-energi.com/pastikan-b30-tetap-jalan-pemerintah-talangi-rp278-triliun-kekurangan-
   dana-insentif-biodiesel/
34 USDA (2020). Biofuels Annual, Indonesia, in https://apps.fas.usda.gov/newgainapi/api/Report/
   DownloadReportByFileName?fileName=Biofuels%20Annual_Jakarta_Indonesia_06-22-2020
35 Fitriani Tupa R. Silalahi, Togar M. Simatupang, Manahan P. Siallagan. Biodiesel produced from palm oil in
   Indonesia: Current status and opportunities[J]. AIMS Energy, 2020, 8(1): 81-101. doi:10.3934/energy.2020.1.81
36 USDA (2020). Biofuels Annual, Indonesia, in https://apps.fas.usda.gov/newgainapi/api/Report/
   DownloadReportByFileName?fileName=Biofuels%20Annual_Jakarta_Indonesia_06-22-2020
37 Kharina, A., Malins, C., & Searle, S. (2016). Biofuels Policy in Indonesia: Overview and Status Report, in https://
   theicct.org/sites/default/files/publications/Indonesia%20Biofuels%20Policy_ICCT_08082016.pdf
38 Coaction Indonesia (2018). Dynamics of Indonesian Biodiesel Downstream and Upstream Industry, in https://
   coaction.id/katalog/summary-dynamics-of-indonesian-biodiesel-downstream-and-upstream-industry/
39 Kharina, A., Malins, C., & Searle, S. (2016). Biofuels Policy in Indonesia: Overview and Status Report, in https://
   theicct.org/sites/default/files/publications/Indonesia%20Biofuels%20Policy_ICCT_08082016.pdf
                                                                                                                          21
40 Ibid.
     41 Kementerian Energi Dan Sumber Daya Mineral (2019). Kebijakan Nasional Energi Baru Terbarukan Dan Konservasi
        Energi, in http://iesr.or.id/wp-content/uploads/2019/11/191216-IESR-Clean-Energy-Outlook.pdf
     42 Peraturan Presiden (2017). Rencana Umum Energi Nasional. In https://sipuu.setkab.go.id/PUUdoc/175146/
        Perpres%2022%20Tahun%202017.pdf
     43 https://www.reuters.com/article/us-indonesia-palmoil/indonesias-freeze-on-palm-oil-plantation-permits-lacks-
        transparency-industry-watchdog-idUSKBN1XG1PT
     44 https://theconversation.com/indonesia-readies-its-green-diesel-these-are-the-likely-social-and-environmental-
        impacts-145044
     45 Andriani, D. (2021). Penyebab Produktivitas Kelapa Sawit Indonesia Kalah dari Malaysia, in https://ekonomi.bisnis.
        com/read/20210129/99/1349409/penyebab-produktivitas-kelapa-sawit-indonesia-kalah-dari-malaysia
     46 Kompas (2021). Produktivitas Sawit Indonesia Masih Kalah dari Malaysia, in https://money.kompas.com/
        read/2017/06/20/131900726/produktivitas.sawit.indonesia.masih.kalah.dari.malaysia?page=all
     47 Rejuvenation is the replacement of less productive, older plants with more productive and profitable new plants.
     48 Dua Tahun Inpres Moratorium Sawit : Pemerintah Perlu ‘Tancap Gas’ Perbaiki Tata Kelola Sawit (2020), in https://
        www.madaniberkelanjutan.id/2020/09/21/dua-tahun-inpres-moratorium-sawit-pemerintah-perlu-tancap-gas-
        perbaiki-tata-kelola-sawit
     49 Dua Tahun Inpres Moratorium Sawit : Pemerintah Perlu ‘Tancap Gas’ Perbaiki Tata Kelola Sawit (2020) in, https://
        www.madaniberkelanjutan.id/2020/09/21/dua-tahun-inpres-moratorium-sawit-pemerintah-perlu-tancap-gas-
        perbaiki-tata-kelola-sawit
     50 Indonesia eyes biodiesel with 40% bio-content during 2021-2022 (2019), in https://www.reuters.com/article/us-
        indonesia-biodiesel-idUSKBN1YE09C
     51 Malins, C. (2017). Driving deforestation: the impact of expanding palm oil demand through biofuel policy. Cerulogy,
        London. https://d5i6is0eze552.cloudfront.net/documents/Publikasjoner/Andre-rapporter/Cerulogy_Driving-
        deforestation_Jan2018.pdf?mtime=20180122234132
     52 The Chain: Indonesia’s New Targets for National Biodiesel Program Could Sharply Increase Pressure on the
        Country’s Remaining Forests (2020), in https://mailchi.mp/chainreactionresearch.com/the-chain-indonesias-
        new-targets-for-national-biodiesel-program-could-sharply-increase-pressure-on-the-countrys-remaining-
        forests?e=e9f4790b10
     53 ICEL. (2020). Berbagai Problematika Dalam UU Cipta Kerja Sektor Lingkungan dan Sumber Daya Alam (Seri
        Analisis 3, Issue brief). ICEL, in https://icel.or.id/wp-content/uploads/ICEL-SERI-ANALISIS-UU-CIPTA-KERJA-
        SEKTOR-LH-DAN-SDA-compressed.pdf
     54 The Omnibus Law also amends Law No. 18 of 2013 on Prevention and Eradication of Forest Destruction in relation
        to certain adjustments regarding sanctions for various violations in forest areas.; Global Compliance News,
        “Indonesia: Omnibus Law – Impacts on Environment and Forestry”, available at https://globalcompliancenews.
        com/indonesia-omnibus-law-impacts-on-environment-and-forestry-12102020/
     55 First Nationally Determined Contribution - Republic of Indonesia, in https://www4.unfccc.int/sites/ndcstaging/
        PublishedDocuments/Indonesia%20First/First%20NDC%20Indonesia_submitted%20to%20UNFCCC%20Set_
        November%20%202016.pdf
     56 First Nationally Determined Contribution Republic of Indonesia (n.d.), in https://www4.unfccc.int/sites/ndcstaging/
        PublishedDocuments/Indonesia%20First/First%20NDC%20Indonesia_submitted%20to%20UNFCCC%20Set_
        November%20%202016.pdf
22
57 Kementerian Energi dan Sumber Daya Mineral (2019). Kebijakan, Regulasi Dan Inisiatif Pengembangan Energi
   Surya Di Indonesia, in http://iesr.or.id/wp-content/uploads/2019/10/2019-10-10-Bahan-Paparan-Akselerasi-PLTS-
   Mencapai-65-GW-pada-2025-IESR.pdf
58 Government regulation 79/2014.
59 Presidential Regulation 22/2017.
60 Nofyanza, S.; Moeliono, M.; Selviana, V.; Dwisatrio, B.; Liswanti, N.; Tamara, A.; Komalasari, M. (2020). Revisiting the
   REDD+ experience in Indonesia Lessons from national, subnational and local implementation. CIFOR Info Brief
   314, in https://www.cifor.org/publications/pdf_files/infobrief/7880-infobrief.pdf
61 Aidenenvironment (2018). Situational Analysis of the Indonesian Palm Oil Sector, Project 3231
62 Apical (Malaysia) Sdn Bhd.
63 Trase (2020). Corporate ownership and dominance of Indonesia’s palm oil supply chains, in http://resources.trase.
   earth/documents/infobriefs/infobrief09EN.pdf
64 The company's subsidiary AAA Oils & Fats Pte. Ltd.is an RSPO member.
65 CDP invites parent companies to disclose, and their disclosure should also cover the direct operations and supply
   chains of all subsidiaries. If the parent company excluded one of their subsidiaries in their disclosure, then they are
   required to state their exclusion in their disclosure with the appropriate reason.
66 About SPOTT (2021), in https://www.spott.org/about/
67 Palm oil: ESG policy transparency assessments (2020), in https://www.spott.org/palm-oil/
68 Assessment scores explained (2021), in https://www.spott.org/assessment-scores-explained/
69 RSPO Certification (2021), in https://rspo.org/certification
70 Darmex Agro Group PT (2020), in https://www.spott.org/palm-oil/darmex-agro-group-pt/#substantiated-concerns
71 Annual Communication of Progress (2019), in https://rspo.org/members/acop
72 D. Garrett, S. Levy, K.M. Carlson, T.A. Gardner, J. Godar, J. Clapp, P. Dauvergne, R. Heilmayr, Y. le Polain de Waroux,
   B. Ayre, R. Barr, B. Døvre, H.K. Gibbs, S. Hall, S. Lake, J.C. Milder, L.L. Rausch, R. Rivero, X. Rueda, R. Sarsfield, B.
   Soares-Filho, N. Villoria,
73 Criteria for effective zero-deforestation commitments, Global Environmental Change, Volume 54, 2019, Pages
   135-147, ISSN 0959-3780,
74 https://doi.org/10.1016/j.gloenvcha.2018.11.003.
75 USDA (2020). Biofuels Annual, Indonesia, from https://apps.fas.usda.gov/newgainapi/api/Report/
   DownloadReportByFileName?fileName=Biofuels%20Annual_Jakarta_Indonesia_06-22-2020
76 Ibid.

                                                                                                                               23
DISCLOSURE INSIGHT ACTION

For more information please contact:

CDP Policy Engagement
Pietro Bertazzi
Global Director, Policy Engagement
pietro.bertazzi@cdp.net

Helen Finlay
Global Senior Policy Manager, Forests
helen.finlay@cdp.net

Nur Maliki Arifiandi
Policy Engagement Manager, Forests
nur.arifiandi@cdp.net

CDP Forests
Rini Setiawati
Forests Manager
rini.setiawati@cdp.net

CDP Worldwide
Level 4
60 Great Tower Street
London EC3R 5AZ
Tel: +44 (0) 20 3818 3900
www.cdp.net

About CDP

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population of over 2.6 billion. Fully TCFD aligned, CDP holds the largest environmental database in the world, and CDP scores are widely
used to drive investment and procurement decisions towards a zero carbon, sustainable and resilient economy. CDP is a founding
member of the Science Based Targets initiative, We Mean Business Coalition, The Investor Agenda and the Net Zero Asset Managers
initiative. Visit cdp.net or follow us @CDP to find out more.
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